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Interpretation Response #13-0169 ([SC Johnson & Son, Inc] [Ms. Georgia Barr])

Below is the interpretation response detail and a list of regulations sections applicable to this response.

Interpretation Response Details

Response Publish Date:

Company Name: SC Johnson & Son, Inc

Individual Name: Ms. Georgia Barr

Location State: WI Country: US

View the Interpretation Document

Response text:

October 23, 2013

Ms. Georgia Barr
SC Johnson & Son, Inc.
1525 Howe Street
Racine, WI 53403-5011

Ref. No. 13-0169

Dear Ms. Barr:

This responds to your August 13, 2013 email regarding the marking of limited quantity packaging under the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).  Specifically, you are requesting an interpretation of the § 172.315(a)(1) size requirements for the limited quantity marking for ground shipments.

In your incoming email, you note that, in order to: (1) meet customer requests for structural perforations and graphics; (2) satisfy production, warehousing, and other governmental requirements for display of information (e.g., bar codes) on the packaging; and (3) satisfy the § 172.304 marking requirements, the limited quantity marking on your packagings would need to be 80 mm on each side.  Additionally, you provide illustrations of these retail packagings.  

It is the opinion of this Office that, to the extent necessary to accommodate pre-printing of the additional information needed with the limited quantity marking, the size of the marking may be reduced to no less than 50 mm on each side.  Based on the illustrations of the retail packagings you provided, these packagings would still satisfy the intent of the limited quantity marking of § 172.315 and the marking requirements of § 172.304 of the HMR.  Specifically, the packaging size appears to require a reduced size marking, the limited quantity marking you depicted is readily visible, and nearby markings do not substantially reduce the effectiveness of the marking given the relative sizes and prominence of the other non-DOT markings on the same side.

I hope this information is helpful.  If you have further questions, please contact this office.

Sincerely,

Robert Benedict
Chief, Standards Development Branch
Standards and Rulemaking Division

172.315, 172.304

Regulation Sections

Section Subject
172.304 Marking requirements
172.315 Limited quantities